Legal

Privacy Policy

Last updated: June 21, 2026

This Privacy Policy explains how Redema ("Redema," "we," "us") collects, uses, discloses, and safeguards information in connection with our website and platform. Redema is a technology provider for licensed Georgia Class B COAM Locations. Please read this Policy together with our Terms of Service and Acceptable Use Policy.

1. Scope

This Policy applies to information we process through our website, the operator dashboard, the clerk terminal application, the player application, and related services (together, the "Service"). It does not apply to third parties we do not control, including the card-issuing partner, sponsor bank, card networks, payment processors, device makers, and app stores, each of which has its own privacy practices.

2. Our roles & the Operator's responsibility

For information about a Location's own business and account, Redema generally acts as a controller. For information about Players that an Operator collects and processes using the Service, the Operator determines the purposes and means of that processing and is responsible for it, including for providing all required notices and obtaining all required consents; in that context Redema generally acts as the Operator's service provider/processor and handles such information on the Operator's behalf and instructions. Redema is not responsible for an Operator's or its Personnel's independent collection, use, disclosure, or security of personal information.

3. Information we collect

Category	Examples
Business & account	Business/legal name, contact name, email, phone, billing and shipping address, and the license numbers you provide to verify your Location and machines.
Player wallet	The limited identifiers needed to create and operate a Player's noncash wallet, as configured by the Operator.
Transaction records	Redemption and load records written to our append-only ledger — amounts, timestamps, Location, machine/ticket references, and related metadata. We do not store full payment card numbers.
Device & technical	App and device identifiers, IP address, log and diagnostic data, and security events.
Usage	How the Service is accessed and used, feature interactions, and analytics.
Communications	Support requests, messages, and your preferences.

4. Sources

We collect information directly from you and your Personnel; automatically through your use of the Service; from your devices; and from service providers and partners (such as our payment processor and the card-issuing partner) as needed to operate the Service.

5. How we use information

To provide, operate, maintain, secure, and improve the Service;
To verify eligibility and the integrity of redemptions and to maintain the ledger;
To detect, investigate, and prevent fraud, misuse, and security incidents;
To process subscriptions, device orders, and billing;
To provide support and send service and administrative communications;
To perform analytics and develop new features;
To comply with legal, regulatory, reconciliation, audit, tax, and recordkeeping obligations; and
To establish, exercise, or defend legal claims and enforce our agreements.

6. Cookies & analytics

Our website and dashboard may use cookies and similar technologies for essential functionality, preferences, security, and analytics. You can control cookies through your browser settings; disabling some may affect functionality. We do not control, and are not responsible for, third-party analytics or advertising practices.

7. How we disclose information

We do not sell personal information, and we do not share it for cross-context behavioral advertising. We disclose information only as follows:

Service providers / processors who perform services on our behalf under contract (hosting and infrastructure, the card-issuing partner, payment processing, communications, analytics, and support), limited to what they need.
To operate the Card, with the issuing partner as needed to provision and support a Player's virtual card.
Legal, safety & compliance: when we believe disclosure is required by law, regulation, legal process, or governmental request, or is necessary to protect rights, safety, property, or the integrity of the Service, or to investigate misuse.
Business transaction: in connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to this Policy.
With your direction or consent.

8. Security

We use administrative, technical, and physical safeguards designed to protect information, including encryption in transit, access controls, least-privilege practices, and an append-only, daily-reconciled ledger. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for safeguarding your credentials, devices, and access. We are not liable for unauthorized access resulting from causes beyond our reasonable control or from your acts or omissions.

9. Retention

We retain information for as long as needed to provide the Service and to satisfy legal, regulatory, reconciliation, tax, accounting, and dispute-resolution requirements, after which we delete or de-identify it. Ledger records may be retained on a long-term basis for integrity and compliance.

10. Your choices & rights

Depending on your role and applicable law, you may request to access, correct, update, or delete certain information, or to limit certain processing, subject to legal and recordkeeping obligations and to verification. Operators are responsible for responding to requests from their own Players regarding information the Operator collects. To make a request, contact us at hello@coamredemption.com. We will not discriminate against you for exercising lawful rights.

11. Children

The Service is intended for licensed businesses and adults and is not directed to children. We do not knowingly collect personal information from children. If you believe a child has provided information, contact us and we will take appropriate steps.

12. Third-party links & services

The Service may link to or rely on third-party sites and services. We do not control and are not responsible for their content, security, or privacy practices. Your use of them is governed by their terms and policies.

13. Changes to this Policy

We may update this Policy from time to time. We will post the updated Policy with a new "Last updated" date, and for material changes may provide additional notice. Your continued use of the Service after changes take effect constitutes acceptance.

14. Contact

Redema · hello@coamredemption.com

© 2026 Redema. An independent technology provider. Not affiliated with, endorsed by, or acting on behalf of the Georgia Lottery Corporation. No cash, change, or currency provided. This page is provided for general information and is not legal advice.